Nutrition guidance recommending nutrient dense foods such as meat and poultry products, including red and processed meats, should be the foundation of government nutrition policy, the North American Meat Institute said May 8 in comments submitted to the USDA and the Department of Health and Human Services regarding the 2015 Dietary Guidelines Advisory Committee Scientific Report.
The comments emphasize the variety of nutrition benefits of meat and poultry products as convenient, direct, and balanced dietary sources of all essential amino acids and rich sources of many micronutrients. The comments also are critical of lean meat’s relegation to mere footnote status in the DGAC report.
“Lean meat’s inclusion in a healthy dietary pattern is supported by the scientific evidence demonstrating its high nutritional value, and the Report’s handling of lean meat represents a sharp, unsubstantiated departure from findings presented in the Dietary Guidelines for Americans, 2010. A review of scientific research reveals that the DGAC’s findings on lean meat conflict with the preponderance of the evidence, which affirms the healthful role lean meat and poultry, including red and processed meats, play in dietary patterns,” the comments state.
NAMI also highlighted the benefits of red and processed meats, noting that 17 of the 25 most popular cuts of beef and seven pork cuts meet the definition of lean by the USDA and many lean, lower in saturated fat and lower sodium processed meats can be purchased. According to a NAMI menu model analysis using the recommendations of the 2010 Dietary Guidelines for Americans, which had previously been shared with the DGAC, a diverse array of processed meats, even when consumed twice daily for one week, allow consumers to stay within daily calorie and nutrient goals, while also helping individuals meet or exceed recommended nutrient intakes.
NAMI also takes issue with the DGAC’s recommendation to reduce consumption of “mixed dishes” with foods from a variety of groups, asserting that these foods often drive consumption of foods and nutrients encouraged by the DGAC, such as vegetables, whole grains, fiber, protein and more.
NAMI’s comments also highlighted several inconsistencies in the way science was evaluated by the DGAC. Overall, more than 70% of the DGAC recommendations were not based on the reviews of the Nutritional Evidence Library, which is designed to reduce bias in scientific analysis by serving as a primary resource to inform the committee about the best available scientific research and answer important food and nutrition-related questions. Conversely, the 2010 DGAC used the NEL for approximately 70% of its recommendations.
The inconsistencies were particularly glaring in the DGAC’s evaluation of red and processed meats. The DGAC ignored its own analysis that the intake of red and processed meats in Mediterranean-style diets was approximately twice the recommended intake of the USDA Food Patterns, and also ignored the result of a study it heavily relied on to make its conclusions on dietary patterns and cardiovascular disease, which found that red meat consumption did not significantly increase the CVD risk.
“The scientific evidence did not fit the bias of the DGAC, which instead recommended against including red and processed meat as components of a healthy diet. The DGAC reinterpreted the Mediterranean diet to be more “healthy” and based on the description “healthy” does not include the consumption of red and processed meats. Because the recommendation to limit intake of red and processed meat is not based on robust scientific evidence, HHS and USDA should not develop dietary guidance recommending limiting the consumption of red and processed meats,” the comments say.
The inconsistencies extend to the DGAC’s evaluation of sustainability. The Sustainability and Food Safety Subcommittee deviated from the evidence review approach used by all other subcommittees because its review depended on lower-quality study designs, and the subcommittee only reviewed a small proportion of the available modeling data, resulting in an underpowered review. NAMI also reiterated its concern that the committee acted outside it authority the scope of its expertise with its recommendations on sustainability and tax policy, stating “Just as it is not appropriate for the person designing a better light bulb to tell Americans how to make a better sandwich so too is it inappropriate for nutrition experts to wander into sustainability recommendations.”
Finally, NAMI recommends that the HHS and USDA develop the final Dietary Guidelines for Americans with the guidance of food scientists and consumer behaviorists, which were each missing from the DGAC.
“Food scientists and behaviorists provide a translation perspective that would have provided biological context resulting in the final DGAC recommendations being more robust and likely achievable. Instead, many of the recommendations lack the scientific rigor to be utilized in developing the final policy document,” the comments say.
A copy of the comments is available here.